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96 documents · 0.26sAllIRCERISAPBGCJoint Board
  1. T.C. Memo. 2016-228 — Suzanne D. Oster Ozimkoski v. Commissioner
    IRCCourt RulingsDec 19, 2016
    …e tax required to be shown on the tax return or $5,000. Sec. 6662(d)(1)(A); Higbee v. Commissioner, 116 T.C. at 448. As stated supra p. 17, under section 7491(c) the Commissioner bears the burden of production with regard to penalties. Higbee v. Commissioner, 116 T.C. at 446. Once the Commissioner has met the burden of…
  2. T.D. 9744 — This document contains final regulations concerning Public Health Services Act sections which are incorporated into section 9815 of the Internal Revenue Code b…
    IRCTreasury DecisionsDec 7, 2015
    ethod is $116. The amount that would be paid under Medicare for the emergency service, excluding any copayment or coinsurance for the service, is $80. (ii) Conclusion. In this Example 5, the plan is responsible for paying $92.80, 80% of $116. The median amount among those agreed to for the emergency service is $115 and…
  3. 121 T.C. No. 19 — Fortunato J. Mendes v. Commissioner
    IRCCourt RulingsDec 11, 2003related by meaning
    f section 6501, 1 section 6651(a)(1), 2 - 37 - 2 (...continued) (2003) ; Janpol v. Commissioner , 102 T.C. 499, 503, 505 (1994); Beard v. Commissioner , 82 T.C. 766, 780 (1984), affd. per curiam 793 F.2d 139 (6th Cir. 1986) ; Unroe v. Commissioner , T.C. Memo. 1985-149; Counts v. Commissioner , T.C. Memo. 1984-561, aff…
  4. T.C. Memo. 2026-68 — Malibu Valley Land, LLC, Spectrum Development, Inc., Tax Matters Partner v. Commissioner
    IRCCourt RulingsAug 17, 2026
    …rtion of an underpayment for which the taxpayer shows reasonable cause and good faith. See Higbee , 116 T.C. at 448. Reasonable cause is determined case by case, considering all pertinent facts and circumstances. Treas. Reg. § 1.6664- 4(b)(1). The inquiry focuses on whether the taxpayer exercised ordinary business care…
  5. 93 T.C. 103; 93 T.C. No. 10 — Gord v. Commissioner
    IRCCourt RulingsJul 26, 1989related by meaning
    OPINION COHEN, Judge: Respondent determined a deficiency of $94,372 in petitioners’ Federal income taxes for 1979. The sole issue remaining for decision is whether petitioners’ income tax should be computed by applying the maximum tax on earned income under section 1348 to the net profits from the smoke shop operated b…
  6. Treas. Reg. § 1.401(a)(9)-9(d) — Life expectancy and distribution period tables.
    IRCRegulationsSep 17, 2024
    …3.1 3.1 3.0 3.0 2.9 114 3.6 3.5 3.3 3.2 3.1 3.0 3.0 2.9 2.9 115 3.6 3.4 3.3 3.2 3.1 3.0 2.9 2.9 2.9 116 3.5 3.3 3.2 3.1 3.0 2.9 2.8 2.8 2.8 117 3.4 3.3 3.1 3.0 2.9 2.8 2.7 2.7 2.7 118 3.3 3.1 3.0 2.8 2.7 2.6 2.6 2.5 2.5 119 3.1 2.9 2.8 2.6 2.5 2.4 2.4 2.3 2.3 120+ 3.0 2.8 2.6 2.5 2.3 2.2 2.1 2.1 2.1 Table 3 to Paragrap…
  7. 125 T.C. No. 5 — 100 Oak Street Corporation v. Commissioner
    IRCCourt RulingsSep 15, 2005related by meaning
    125 T.C. No. 5 UNITED STATES TAX COURT SERVICE EMPLOYEES INTERNATIONAL UNION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, . Respondent 100 OAK STREET CORPbRATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 8398-04L, 8399-04L. Filed September 15, 200 . saan. Ps are qualified labor. organi…
  8. Treas. Reg. § 1.430(f)-1(g) — Effect of prefunding balance and funding standard carryover balance.
    IRCRegulationsSep 9, 2016
    …ctive interest rate of 5.5% for 2009. Accordingly, the prefunding balance used for this purpose is $116,050 [($125,000 − $15,000 deemed reduction) × 1.055].(iii) The fair market value of plan assets used for the December 31, 2010, valuation is $883,950 ($1,000,000 − $116,050). Example 11.(i) The facts are the same as i…
  9. T.C. Memo. 2022-69 — Clair R. Couturier, Jr. v. Commissioner
    IRCCourt RulingsJul 6, 2022related by meaning
    s are to the Tax Court Rules of Practice and Procedure. Served 07/06/22 2 [* 2 ] under section 4973, plus associated additions to tax and penalties. 2 Currently before the Court is petitioner’s Motion for Summary Jud gment under Rule 121. Petitioner contends that the IRS “is precluded as a matter of law from asserting …
  10. Notice 2024-3 — 2023 Cumulative List of Changes in Plan Qualification Requirements for Defined Contribution Qualified Pre-approved Plans
    IRCNoticesJan 8, 2024
    …000 or 150% of the regular catch-up limit for 2025, indexed for inflation. 10. Section 415: Section 116 of the SECURE Act amends section 415(c) of the Code to treat difficulty of care payments that are excluded from gross income as compensation for determining retirement contribution limitations. Notice 2020-68 provide…
  11. T.C. Summary Opinion 2013-96 — Samuel & Lilian Brach v. Commissioner
    IRCCourt RulingsDec 2, 2013related by meaning
    T.C. Summary Opinion 2013-96 UNITED STATES TAX COURT SAMUEL BRACH AND LILLIAN BRACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15460-12S. Filed December 2, 2013. Ronald Jay Cohen, for petitioners. Gennady Zilberman, for respondent. SUMMARY OPINION ARMEN, Special Trial Judge: This case was h…
  12. PLR 202430007 — Employees of Businesses Under Common Control
    IRCPrivate Letter RulingsJul 26, 2024
    …in section 2301 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub . L. No. 116-136, 134 Stat. 281 (Mar. 27, 2020), as amended by section 206 of the Taxpayer Certainty and Disaster Tax Relief Act (Relief Act), which was e nacted as Division EE of the Consolidated Appropriations Act, 2021, Pub. L…
  13. T.C. Memo. 2023-140 — Kunjlata J. Jadhav & Jalandar Y. Jadhav v. Commissioner
    IRCCourt RulingsNov 21, 2023
    …ome forward with persuasive evidence that the penalt ies are inappropriate. See § 7491(c); Higbee , 116 T.C. at 446 – 47. Petitioners may meet their burden by proving that they acted with reasonable cause and in good faith with respect to the underpayment s . See § 6664(c)(1); see also Higbee , 116 T.C. at 447; Treas. …
  14. T.C. Memo. 2012-104 — Jerald W. & Claudia K. White v. Commissioner
    IRCCourt RulingsApr 11, 2012
    … 54 - evidence indicating that it is appropriate to impose the penalty. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Once the Commissioner meets his burden of production, however, the burden of proof remains with the taxpayer, including the burden of proving that the penalty is inappropriate because of reasona…
  15. T.C. Memo. 1996-556 — Alfred P. Duffy v. Commissioner
    IRCCourt RulingsDec 23, 1996related by meaning
    1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. T.C. Memo. 1996-556 UNITED STATES TAX COURT ALFRED P. DUFFY, Petitioner v . COMMISSIONER OF INTERNAL REVENUE, Respo…
  16. 115 T.C. No. 5 — Wan B. & Cecilia Lo v. Commissioner
    IRCCourt RulingsJul 31, 2000
    …deduct its contributions to the Marlton Plan and increased the Los’ income by $102,500 in 1993 and $116,212 in 1994 to reflect the following adjustments: 1993 1994 Contributions to the Marlton Plan $100,000 $120,000 Administrator’s fees 2,500 500 Subtotal 102,500 120,500 Less: P.S. 58 costs included in income -0- 4,288…
  17. T.C. Memo. 1996-502 — Elaine S. Bennett v. Commissioner
    IRCCourt RulingsNov 7, 1996related by meaning
    …tion because we might deem its effects susceptible of improvement. Commissioner v. Lundy , 516 U.S. 116 S. Ct. 647, 656-657 (Jan. 17, 1996) (citing Badaracco v. Commissioner , 464 U.S. 386, 398 (1984)). Accordingly, in order to give effect to our disposition of the disputed issue, as well as respondent's concession, an…
  18. T.C. Summary Opinion 2014-18 — Thomas Wesley Alexander & Sylvia Alexander v. Commissioner
    IRCCourt RulingsFeb 26, 2014
    …pect to the liability of any individual for penalties and additions to tax. Higbee v. Commissioner, 116 T.C. 438, 446 (2001); Trowbridge v. Commissioner, T.C. Memo. 2003-164, aff'd, 378 F.3d 432 (5th Cir. 2004). In order to meet the burden of production under section 7491(c), the Commissioner need only make a prima fac…
  19. T.C. Memo. 2016-31 — Brian M. Polowniak v. Commissioner
    IRCCourt RulingsFeb 25, 2016
    …g travel expenses of $274,830 and meals and entertainment expenses of $24,250, for a net profit of $116,595. Petitioner reported Strategies' income of $116,595 on a Schedule E attached to his 2005 Form 1040. V. Notices of Deficiency On June 9, 2011, respondent issued a notice of deficiency to petitioner for 2004.6 Resp…
  20. 121 T.C. No. 14 — Jimmy D. & Marlene M. Morloc Weaver v. Commissioner
    IRCCourt RulingsOct 8, 2003related by meaning
    ng this amount. Subsequently, J.D. merged into Clarkston pursuant to section 368, and filed a final tax return as a C corporation for the period ended April 30, 2000. The $90,000 intercompany note was during the final return year of J.D. eliminated by book entry as a result of the merger. - 5 - Discussion Respondent’s …